The Department of Health and Human Services made its deadline and established the metrics to measure “widespread interoperability” as required by the Medicare Access and CHIP Reauthorization Act (MACRA) by July 1.
And, perhaps not surprisingly, HHS went the easy route. But it still leaves open several troublesome questions.
The Office of the National Coordinator for Health IT stated in its April request for information that it planned on using measures from the Meaningful Use program, and was considering measuring the proportion of providers sending, receiving, finding/querying and integrating the information into a patient’s medical record, as well as the proportion of providers who use the electronic information received from outside sources.
And that’s exactly what ONC will do. Despite receiving more than 80 comments, ONC is sticking to its original plan.
Not that I blame ONC. It’s a tall task to measure interoperability. These are interoperability measures that it’s used to. There was a tight deadline to establish the metrics. ONC also acknowledged that it was constrained by MACRA’s “specific parameters.”
The agency did give a nod to the comments, pointing out that commenters focused mainly on four issues:
- The reporting burden on providers;
- Whether the scope should be broad enough to include providers not in the incentive programs;
- That the measurement should go beyond the exchange of information and also examine the usability and usefulness of the information as well as outcomes
- The need to recognize the complexity of measuring interoperability fully
ONC tried to accommodate some of those concerns. It will measure interoperability by relying on existing nationally representative surveys from the American Hospital Association and the Centers for Disease Control and Prevention. The agency assured stakeholders that while MACRA focuses on “meaningful users,” ONC has a broader vision more in line with its roadmap and will expand its measurement to other providers in the care continuum in the short term. It also will add in outcomes measures in the long term.
It all sounds okay--until you take a closer look. And then you realize that there's a lot of substance missing.
For instance, what proportion of providers will indicate that there’s more data exchange occurring and how it’s being used? Is it a set percentage? Is the proportion on a sliding scale that changes by quarter, or year, or provider type? Would the proportion of those “sending” be a different percentage from those “integrating?"
Additionally, who is setting these goals? Will they be made public? And how often will the results be made public?
Moreover, ONC appears to be willing to rely on provider self-reporting in the surveys. How reliable are these surveys? Or would providers feel compelled to answer in a more self-serving way, knowing that their answers may affect the interoperability measurements?
Also, according to ONC, the metrics will help “inform” other efforts, such as the pledges made by the private sector to improve interoperability, information from vendors regarding costs and implementation issues and the creation of mobile apps that patients can use. How will the survey measurements affect these other activities? Or is ONC simply stating that the measurements may help? If the results aren’t reported frequently enough, I’m not sure how well they’ll “inform” others.
Perhaps most importantly, what will this endeavor actually accomplish besides meeting a statutory mandate? Will it really help increase data exchange? Improve EHR design? Will it help support struggling health information exchanges? Improve the security of data being shared? And if so, how?